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OFAC General License

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On September 8, 2022, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) reissued Russia-related General License 13B, “Authorizing Certain Administrative Transactions Prohibited by Directive 4 under Executive Order 14024” (“GL 13B”), which amends and replaces the former GL 13A. The authorization of GL 13B is extended through 12:01 a.m. Eastern time on December 7, 2022.  This is the second time an extension has been granted.  GL 13A was previously set to…

On August 19, 2022, the Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) replaced existing General License (“GL”) 38 with GL 38A and issued a new GL 50. These GLs authorize certain activities otherwise prohibited by EO 14024, which targets, among other things, specific sectors (including the financial services sector) of the Russian economy. Our prior blog post regarding EO 14024 and the financial sanctions imposed thereunder can be found here, here, here,…

On August 2, 2022, the US Commerce Department’s Bureau of Industry and Security (“BIS”) updated its list of aircraft that have flown into Russia or Belarus in apparent violation of the Export Administration Regulations (“EAR”) (the “List”) by adding 25 foreign-produced aircraft. These aircraft were identified by BIS as subject to the EAR because they incorporate controlled US-origin content exceeding applicable de minimis amounts (i.e., greater than 25% by value) and having apparently violated the…

On July 22, 2022, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) issued two new Russia-related general licenses (“GLs”), published two new FAQs regarding these GLs, and amended two existing Russia-related FAQs. The new GLs authorize certain activities related to Russian bonds and securities and appear intended solely to help US investors wind down their financial exposure to Russia and settle certain credit default swaps following Russia’s recent June default on…